Original submission

Policy SS13: Marks Tey
As mentioned above, we support that the wider Marks Tey area has been identified as the location of a proposed allocation for a Garden community. Its effective transport connections and proximity to Colchester and Braintree, make Marks Tey a suitable location for substantial new development.

It is recognised that the Neighbourhood Plan will provide scope for the allocation of any small parcels of land for development outwith the Garden communities. As indicated above, we strongly support the proposed West Colchester Garden community and the inclusion of our client's site within the broad location. In addition to this, the site on its own is also deliverable and developable given it is previously developed and in a sustainable location. Policy SG2 recognises that the borough has limited and diminishing supply of brownfield sites that can contribute to accommodating new growth, and so our client's site would make a valuable contribution in this regard.

In principle, our client's site is available and deliverable as part of the garden community. Were the strategic development not to proceed it should also be recognised that this site would represent an appropriate previously developed site opportunity for the securing of sustainable development in any event or in turn for consideration through the Neighbourhood Plan.

Appendix 1 section 15.22 provides further details on Marks Tey Allocations and that Policy SS13 outlines that growth within the Marks Tey area will be guided by Part One of the Colchester Borough Local Plan (Policy SP9) for strategic issues and the Marks Tey Neighbourhood Plan. Whilst no sites are allocated for Marks Tey as part of the Local Plan Preferred Options, it is recognised the reasons for non-allocation are that any sites would be allocated through the Neighbourhood Plan or joint work in respect of the proposed Garden community to the west of Colchester. However the call for sites and SLAA identified sites are considered in the SA as reasonable alternatives for exploration and assessment. Our clients land is listed as WST01 London Road, Marks Tey for housing with a potential yield of 60-70 units.

Table 96 assesses the sites in the broad area for comparison purposes. However having reviewed the assessment of WST01 against the SA's Table 5: The SA Site Assessment Pro Forma, there are a number of queries:

Objective 2 - It is noted for PDL/Greenfield, it is scored as an uncertain impact. It is not clear why this conclusion has been reached. The site is currently in use for mostly storage of caravans and it is not a greenfield site. As such development of the site would reduce the need for development on greenfield land. It should therefore be scored a significantly positive impact as it is 100% brownfield.

For ALC, the site is scored as having a negative impact. However the site is not in agricultural use, so it cannot score negatively against this assessment criterion. The impact should therefore be significantly positive.

Objective 4 - For access arrangements, the site is rated as having uncertain impacts. However details on access were submitted to the Council in September 2015, indicating how suitable access could be provided. We have written separately (see copy attached) about this in relation to the SLAA and SBR, as we are concerned that this information was not taken into account.

Objective 7 - For cultural heritage, there is an error as the site is marked as a negative impact. However table 5: The SA Site Assessment Pro Forma states a negative impact is not applicable for this assessment criterion. It is recognised that there are a number of listed buildings to the south at Marks Tey Hall, however it is not considered there would be a negative impact, with substantial scope to provide an open space buffer with appropriate landscaping to safeguard the setting of the heritage assets.

Overall, having reviewed the site against the SA Site Assessment Pro Forma, as indicated in the SA assessment it already scores well in terms of achieving the sustainable objectives and it is comparative to the other sites assessed, but as above there are a number of other areas that make a significant positive impact that have not been reflected in the SA. This further reinforces the suitability of the site for development.

It is important that the Local Plan and any subsequent Masterplan Framework foster an equitable approach to inclusion of land within the strategic Garden Communities including equalisation to ensure that current site circumstances (such as PDL status and existing use value) are fully accounted for, in order to maximise the deliverability of proposals. As previously mentioned, our client supports inclusion of his land within the proposed Garden Community, but remains keen for its appropriateness for development in any event to also be acknowledged.